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Barnum v. Equifax Information Services, LLC

United States District Court, D. Nevada

April 12, 2018

SHARON BARNUM, JERRY P. CABEBE, ROBERT SUSTRIK, and all similarly situated individuals, Plaintiffs,
v.
EQUIFAX INFORMATION SERVICES, LLC, Defendant.

          Bradley T. Austin Snell & Wilmer L.L.P. Zachary A. McEntyre, Misty L. Peterson, Bryan E. Zubay King & Spalding LLP Attorneys for Defendant Equifax Information Services, LLC

          Matthew I. Knepper, Esq., Miles N. Clark, Esq. KNEPPER & CLARK, LLC David H. Krieger, Esq. HAINES & KRIEGER, LLC Attorneys for Plaintiffs

          STIPULATION TO EXTEND DISCOVERY DEADLINES [FOURTH REQUEST]

         Pursuant to Fed.R.Civ.P. 26(f), and Local Rule 26-1, Plaintiffs SHARON BARNUM and ROBERT SUSTRIK (“Plaintiffs”), Defendant EQUIFAX INFORMATION SERVICES, LLC (“Equifax”); (together with Plaintiff, the “Parties”), by and through their attorneys, hereby stipulate to extend discovery deadlines and other deadlines in the February 16, 2018 Scheduling Order as follows:

         1. Initial Disclosures.

         The parties do not propose any changes to the form of disclosures required pursuant to Federal Rule 26(a). The Parties already served their initial disclosures.

         2. Completed Discovery.

         This is the fourth stipulation to extend discovery deadlines. The stipulation is filed in good faith and is not intended to cause delay.

         1. On February 28, 2017, the Court entered its Initial Scheduling Order and Protective Order.[1] The Scheduling Order set discovery to close on August 7, 2017.[2]

         2. On May 22, 2017, the Court granted the parties first stipulation to extend discovery 90 days.[3]

         3. Between May 30, 2017 and October 20, 2017, the Parties engaged in extensive discovery, including exchanging written discovery responses, producing documents, and taking depositions of Plaintiffs.

         4. On October 20, 2017, the Court granted a 60-day extension of discovery, setting the close of discovery at January 8, 2018.

         5. Between October 20, 2017 and the present, Plaintiffs deposed two Rule 30(b)(6) witnesses of Equifax and served additional written discovery, to which Equifax timely responded. The Parties also engaged in extensive discussions regarding outstanding discovery issues.

         6. On December 21, 2017, the Court entered a Scheduling Order setting discovery to close on April 23, 2018.

         7. On January 19, 2018, in accordance with the Court's instructions, the Parties filed a Joint Statement.

         8. On February 16, 2018 the Court entered a Scheduling Order[4] setting certain deadlines, inter alia, Initial Expert Disclosures and ...


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